COMMISSIONER OF INCOME TAX vs. MENTOR GRAPHICS (NOIDA) PVT.LTD

The appeal is allowed

section 92C on the basis of such material or informaction or document available with him. After the Transfer Pricing Officer determines the arm’s length price, it is incumbent upon him to send a copy of the order to the assessing officer and to the assessee. In the present case what has happened is that the Transfer Pricing Officer

DCIT, CIRCLE- 16(2), NEW DELHI vs. MENETA AUTOMOTIVE COMPONENTS PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

5. The Hon’ble Supreme Court has held in THE PRINCIPAL COMMISSIONER OF INCOME TAX-4, MUMBAI M/s. S.G. ASIA HOLDINGS (INDIA) PVT. LTD. that in view of the transfer pricing guidelines issued by the CBDT in Instruction No.3/2003 the Tribunal was right in observing that by not making reference to the TPO, the Assessing Officer had breached the mandatory

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

17 of 45 matches with the comparables would result in affirmation of the transfer price as the arm‘s length price. Then to make a comparison of a horizontal item without segregation would be impermissible. (viii) The Bright Line Test was judicial legislation. By validating the Bright Line Test the Special Bench in LG Electronics Case went beyond Chapter

MARUTI SUZUKI INDIA LTD vs. COMMISSIONER OF INCOME TAX

The appeals are allowed in the above terms, but with no orders as to costs

17 of 45 matches with the comparables would result in affirmation of the transfer price as the arm‘s length price. Then to make a comparison of a horizontal item without segregation would be impermissible. (viii) The Bright Line Test was judicial legislation. By validating the Bright Line Test the Special Bench in LG Electronics Case went beyond Chapter

DCIT, CC-29, NEW DELHI vs. DHARAMPAL SATYALPAL LTD., NEW DELHI

Bench: Shri G. S. Pannu & Shri Yogesh Kumar U.S.I.T.A. No. 1977/Del/2020 (A.Y 2014-15)

5-year period of 11.22%, which he considered for BB rated bonds yield 20% more than such bonds and accordingly held that 16.31% would be return rate. Therefore he calculated interest applying rate of interest at 16.31 percentage and computed interest that should have been charged by assessee of D 110997973/- whereas assessee has booked interest

MANKIND PHARMA LIMITED,DELHI vs. DCIT, CIRCLE-1(1)(1), MEERUT

In the result, the additional Ground No

Bench: Shri Challa Nagendra Prasad & Shri Pradip Kumar Kedia

D Centres and having fulfilled the conditions of section 35(2AB) of the Act, is entitled to weighted deduction in respect of the entire gross expenditure incurred on scientific research. 5.2 That the assessing officer erred on facts and in law in allowing deduction under section 35(2AB) of the Act only to the extent of expenditure approved by Department

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

5 of 32 cause notice („SCN‟) requiring the Assessee to explain why the lease agreement should not be treated as a transaction in the nature of sale of the movable/depreciable assets and capital gain not be charged under Section 45 read with Section 50 of the Act. In respect of the said SCN, the Assessee replied on 25th March

TELETUBE ELECTRONICS LTD

The appeal of the Assessee is allowed

5 of 32 cause notice („SCN‟) requiring the Assessee to explain why the lease agreement should not be treated as a transaction in the nature of sale of the movable/depreciable assets and capital gain not be charged under Section 45 read with Section 50 of the Act. In respect of the said SCN, the Assessee replied on 25th March

THE PR. COMMISSIONER OF INCOME TAX -4 vs. HEADSTRONG SERVICES INDIA PVT. LTD.

d) report, if any, of the Assessing Officer, Valuation Officer or Transfer Pricing Officer or any other authority; (e) records relating to the draft order; (f) evidence collected by, or caused to be collected by, it; and (g) result of any enquiry made by, or caused to be made by, it. (7) The Dispute Resolution Panel may, before issuing

ECOENERGY INSIGHTS LTD ( FORMERLY KNOWN AS CHUBB ALBA CONTROL SYSTEMS P.LTD),NEW DELHI vs. DCIT, CIRCLE-4(2), NEW DELHI

In the result, the appeal filed by the assessee is partly allowed as indicated above

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaecoenergy Insights Ltd., Vs. Dcit, (Formerly Known As Chubb Alba Control Circle 4 (2), Systems P. Ltd.), New Delhi. Ground Floor, 18, Netaji Subhash Marg, Daryaganj, New Delhi – 110 002. (Pan :Aaaca0031C) (Appellant) (Respondent) Assessee By : Shri Nageshwar Rao, Advocate Shri Parth, Advocate Shri Pratik Rath, Advocate Revenue By : Shri S.K. Jadhav, Cit Dr Date Of Hearing : 12.08.2025 Date Of Order : 10.11.2025 O R D E R Per S. Rifaur Rahman: 1. This Appeal Preferred By The Assessees Is Directed Against The Assessment Order Dated 25.07.2022Passed By The Assessment Unit, Income Tax Department Under Section 147 Read With Section 144C(13) R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Ay 2018-19 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act.

Section 144B(5) of the Act. Thus, the assessment proceedings are vitiated in law and liable to be quashed. Grounds against addition proposed in relation to transfer of specified asset 3. That on the facts and circumstances of the case and in law, the impugned order is bad in law as the adjustment made in relation to transfer of specified

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. ACIT, CIRCLE-25(1) , NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

D E R PER M. BALAGANESH, AM 1. Assessee M/s. Tupperware Aker Powergas Pvt. Ltd. (hereinafter referred to as „assessee) by filing the present appeal sought to set aside the impugned order dated 13.01.2022 for AY 2017-18 and 31.07.2022 for AY 2018-19 passed by the Assessing Officer (AO) inconsonance with the order passed by the Dispute Resolution Panel

TUPPERWARE INDIA PRIVATE LIMITED,NEW DELHI vs. DCIT,CIRCLE-25(1), NEW DELHI

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

Bench: Shri Mahavir Singh & Shri M. Balaganesh

D E R PER M. BALAGANESH, AM 1. Assessee M/s. Tupperware Aker Powergas Pvt. Ltd. (hereinafter referred to as „assessee) by filing the present appeal sought to set aside the impugned order dated 13.01.2022 for AY 2017-18 and 31.07.2022 for AY 2018-19 passed by the Assessing Officer (AO) inconsonance with the order passed by the Dispute Resolution Panel

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-Section (3) of Section 92CA of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45. Provision for constitution of alternate dispute resolution mechanism 45.1 The dispute resolution mechanism presently in place is time consuming and finality

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-Section (3) of Section 92CA of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45. Provision for constitution of alternate dispute resolution mechanism 45.1 The dispute resolution mechanism presently in place is time consuming and finality

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-Section (3) of Section 92CA of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45. Provision for constitution of alternate dispute resolution mechanism 45.1 The dispute resolution mechanism presently in place is time consuming and finality

DCIT, NEW DELHI vs. I ENERGIZER HOLDINGS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-Section (3) of Section 92CA of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45. Provision for constitution of alternate dispute resolution mechanism 45.1 The dispute resolution mechanism presently in place is time consuming and finality

DCIT, NEW DELHI vs. ISERVICES INVESTMENTS LTD., NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-Section (3) of Section 92CA of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45. Provision for constitution of alternate dispute resolution mechanism 45.1 The dispute resolution mechanism presently in place is time consuming and finality

DCIT, NEW DELHI vs. M/S WICKWOOD DEVELOPMENT LTD.,, NEW DELHI

In the result, the Cross Objections of the assessees are allowed and consequently the appeals of the revenue are liable to be dismissed

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

Transfer Pricing Officer passed under sub-Section (3) of Section 92CA of the Act. Explanatory Note to Finance (No. 2) Act: CBDT Circulars: 17. We have gone through the Circular No. 5/2010 dated 03.06.2010 which reads as under: “45. Provision for constitution of alternate dispute resolution mechanism 45.1 The dispute resolution mechanism presently in place is time consuming and finality